The Court of Appeals of Virginia ruled against the Hanover sheriff, who said he could redact the names of 220 police officers from a spreadsheet of salary information because those officers might one day be used in undercover operations. “Hypothetical future undercover operations, by their very nature as ‘hypothetical,’ are not yet a reality and consequently do not have ‘tactical plans,’ ‘staffing,’ or ‘logistics’ to be disclosed. The possibility of the future assignment of 220 officers to undercover duty is merely speculative.”